Foreign domiciles and non-residents

United Kingdom

02/13/2019

Taxation

Meeting points

Key points – Challenging a charge to tax under the transfer of assets abroad legislation in ITA 2007, Pt 13 ch 2. – The protection of settlements from ‘tainting’. – An adjuster clause may provide some protection from inadvertent tainting of trust assets. – Increasingly, HMRC seems to be challenging claims to non-domicile status. – Rules to counter the enveloping of interests within overseas structures include provisions on relevant loans. – A new capital gains tax charge on non-UK residents disposing of UK property interests that derive at least 75% of their value from UK land (continue)

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